HRC Reporting Services in UAE | High-Risk Country Reports

HRC Reporting Services in the UAE

If your UAE business sends money to, or receives money from, a country on the FATF's highest-risk list, the UAE Financial Intelligence Unit (FIU) expects to hear about it. You tell them through the goAML portal using a High-Risk Country Transaction Report (HRC).

Trigger: Transactions linked to high-risk countries
FATF call-for-action list: DPRK, Iran, Myanmar
goAML template: HRC
Legal basis: CR 134/2025, Art. 23

Through our HRC Reporting Services, our team helps you spot which payments are caught, prepare the HRC and handle what comes next. Businesses without a goAML login can have their goAML registration completed by us as part of the service.

What Is an HRC Report?

An HRC is a goAML report used for transactions connected to countries the Financial Action Task Force (FATF) calls "high-risk jurisdictions subject to a call for action". It is about the country link, not about suspicion. Even a normal, honest payment can need an HRC.

FATF High-Risk Countries List 2026

According to the FATF's public statement of June 2026, the countries subject to a call for action are:

Democratic People's Republic of Korea (North Korea)
Iran
Myanmar

The FATF reviews this list three times a year, in February, June and October. Always check the latest version before deciding whether a payment is reportable.

FATF Grey List vs Blacklist: Which One Matters for HRC?

People often mix these up. The blacklist is the "call for action" list above, and it drives HRC reporting. The grey list ("jurisdictions under increased monitoring") is longer and covers countries working to fix their weaknesses. Grey-list countries call for extra care in your risk assessment, but they are not what the HRC is designed for.

UAE Laws on High-Risk Country Transactions

UAE law requires extra care with transactions linked to high-risk countries, and requires you to follow the countermeasures set by your supervisor and the National Committee. The latest Ministry circular confirms that these transactions are reported on goAML using the HRC template. The rules below set out what is expected:

“shall apply Enhanced Customer Due Diligence measures proportionate to the level of risk arising from a Business Relationship or Transactions with a natural or legal person from countries identified by the National Committee as high-risk”
Cabinet Resolution No. 134 of 2025, Article 23(1)

Law and article	What it means for your business
CR 134/2025, Art. 23(1)	Apply enhanced due diligence to transactions with people or companies from high-risk countries.
CR 134/2025, Art. 23(2)	Follow any countermeasures your supervisor or the National Committee sets for those countries.
CR 134/2025, Art. 5(1)(a)	Country and geographic risk is one of the risk factors you must weigh before deciding how much checking a transaction needs.
CR 134/2025, Art. 5(2)(c)(2)	Get extra information on the reasons for expected or completed transactions.
CR 134/2025, Art. 5(2)(c)(5)	Increase ongoing monitoring and pick out transaction patterns that need closer review.
FDL 10/2025, Art. 19(1)(a)	Identify, assess, document and keep updating the money laundering risks in your business.
Ministry of Economy and Tourism Circular No. (2) of 2026 (14 September 2026)	For DNFBPs it supervises, the Ministry confirms that transactions with black-list countries are reported to the FIU using the existing goAML High-Risk Jurisdiction template, alongside enhanced due diligence.

Which Transactions Need an HRC?

In practice, an HRC is usually needed when money crosses borders through a bank or remittance channel and touches a listed country. For example:

A wire transfer to, or from, a bank in a listed country.
Money routed through a listed country on its way to the UAE.
A payment involving a customer, owner, signatory or senior manager who lives in, holds nationality of, or is registered in a listed country.
Payment for goods shipped to or from a listed country.

There is no minimum amount. Purely local payments that do not use international banking or remittance channels, such as a cash currency exchange with no transfer, are generally outside HRC reporting.

HRC Example

A UAE trading company receives a bank transfer for a shipment. The paying company's real owner lives in a listed country. Nothing about the deal looks criminal, but the country link makes it reportable. The compliance officer files an HRC, applies enhanced due diligence and follows any instruction the FIU sends.

HRC vs HRCA: Transaction or Activity?

If you have the payment details, use the HRC. If the link to a listed country comes through an activity, such as onboarding or an enquiry, and there is no transaction to describe, use the HRCA (High-Risk Country Activity Report) instead.

What Happens After You File an HRC?

Follow any instruction the FIU or your supervisor sends about the transaction, and keep applying enhanced due diligence to the customer. If anything about the deal is also suspicious, file an STR as well. We help you track FIU feedback, record the FIU's response and decide the next step.

How Our HRC Reporting Service Works

HRCs are sent from your organisation's own goAML login, which you get through SACM registration with the FIU. Once you have access, we:

01
Map your exposure: list customers, owners and payment routes with links to listed countries.
02
Check each payment: origin, destination, intermediary banks and parties involved.
03
Collect details: amounts, dates, currencies, accounts and IDs.
04
Build the HRC: enter complete transaction and party data in goAML.
05
Submit and track: your compliance officer submits it and we watch for FIU feedback.
06
Document EDD: record the extra checks carried out on the relationship.

Common HRC Mistakes

Using an old FATF list.
Checking the customer but not the real owner or the payment route.
Confusing the grey list with the call-for-action list.
Ignoring an FIU or supervisor instruction about the transaction.
Forgetting that a suspicious case also needs an STR.

Penalties for Ignoring High-Risk Country Rules

Not applying the required measures breaches Cabinet Resolution No. (134) of 2025. Under Article 17 of Federal Decree-Law No. (10) of 2025, supervisors can issue warnings, impose penalties ranging from AED 10,000 up to AED 5 million for each breach, and restrict or withdraw the licence.

Why Choose Our HRC Reporting Services?

We track every FATF update so you do not have to.
We look beyond the customer to owners and payment routes.
We prepare complete reports that goAML accepts first time.
We support you through FIU follow-ups and enhanced checks.

Frequently Asked Questions

Which countries are on the FATF high-risk list in 2026?

As of June 2026, the countries subject to a call for action are North Korea, Iran and Myanmar.

Is the FATF grey list the same as the blacklist?

No. The blacklist (call for action) drives HRC reporting. The grey list covers countries under increased monitoring and calls for risk-based extra care.

Is there a minimum amount for an HRC?

No. The report depends on the country link, not the value.

Do I need to suspect a crime to file an HRC?

No. If the transaction is also suspicious, file an STR as well.

Dealing with high-risk countries?

Let us check your exposure and file accurate HRC reports from your goAML account.